Legal Opinion

Sperry & Hutchinson Co. v. Department of Revenue

Oregon Tax Court

Decided September 24, 1973PublishedCited by 1 opinion

1Opinion of the Court

Carlisle B. Roberts, Judge.

The plaintiff has appealed from the Department of Revenue’s Order No. 1-71-19, imposing additional corporation excise taxes for the tax years 1961, 1963, 1964 and 1965, pursuant to ORS ehs 314 and 317. The question to be resolved is whether certain interest income received by the plaintiff from investment securities is apportionable in part to Oregon pursuant to the state’s three-factor apportionment formula. Plaintiff is a New Jersey corporation with a New York business domicile. It does business in 48 states, including Oregon, selling a promotional service which…

2Cases cited7 opinions

  1. Northwestern States Portland Cement Co. v. MinnesotaSupreme Court of the United States · 1959
  2. Donald M. Drake Company v. Department of RevenueOregon Supreme Court · 1972
  3. Great Lakes Pipe Line Co. v. Commissioner of TaxationSupreme Court of Minnesota · 1965
  4. Montgomery Ward & Co. v. Commissioner of TaxationSupreme Court of Minnesota · 1967
  5. Cleveland-Cliffs Iron Co. v. Corporation & Securities CommissionMichigan Supreme Court · 1958

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3Cited by1 opinion

  1. Coca Cola Co. v. Department of RevenueOregon Tax Court · 1974

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